The Singapore Badminton Association Privacy Policy
Respecting and protecting the privacy of individuals is important to the Singapore Badminton Association (“SBA”), therefore SBA conducts its operations in compliance with applicable laws on personal data protection and data security.
This Privacy Policy sets out the manner in which SBA collects, uses and manages and protects personal data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 (“PDPA”).
This Privacy Policy applies to all individuals who provide SBA with personal data or whose personal data is otherwise collected, used and/or disclosed by SBA in connection with and/or for the purpose of its operations.
For the avoidance of doubt, this Privacy Policy forms part of the terms and conditions, if any, governing an individual’s specific relationship with SBA and should be read in conjunction with such terms and conditions. In the event of any conflict or inconsistency between the provisions of this Privacy Policy and the said terms and conditions, if any, the provisions of the terms and conditions shall prevail to the fullest extent permissible by law.
Visitors to the SBA’s website are deemed to have agreed to the terms and conditions of this Privacy Policy.
Collection of Personal Data
SBA will only collect, use or disclose an individual’s personal data which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an individual’s interaction or relationship with SBA, personal data which the specific nature of an individual’s interaction or relationship with SBA, personal data which SBA collects, uses or discloses concerning an individual may vary. The types of data collected by the SBA may include, but is not limited to:
- Personal information including an individual’s name, gender, age, date of birth, citizenship, identification numbers;
- Contact information including telephone numbers, addresses, personal email addresses, etc.;
- Payment Information including details of an individual’s CPF account, credit card(s), bankaccount(s), etc.;
- Employment information including employment history and details of former employers
- Qualification information including academic qualifications, sports achievements, etc.;
- Resume, such as an individual’s work resume for employment purposes or sports resume for application of sports membership, etc.;
- Family information including the name, relationship, contact information of the individual’s next of kin, spouse and children;
- Preferences information, such as details of the individual’s personal preferences or other special requests or medical conditions applicable to the individual;
- Personal interest information, for example the individual’s hobbies, interests, etc.;
- Membership information including memberships with other clubs or associations;
- Technical information gathered automatically by our computer systems/website, etc.; and
- Other information including photographs, videos and CCTV recordings of the individual and any other information that the individual may from time to time provide SBA through the course of an individual’s interactions with SBA.
Purpose of Use
SBA may collect, process, use and/or disclose an individual’s personal data for the following purposes:
- processing, administering and/or managing an individual’s relationship with SBA, including providing him or her with the services and benefits of SBA;
- providing information about SBA’s services, facilities and/or other benefits being offered and made available;
- responding to your complaints, queries and/or requests;
- evaluating the individual’s suitability and eligibility to be a member of SBA, including but not limited to reviewing and approving the individual’s application(s) for SBA’s services and benefits, conducting initial and anticipatory credit checks and assessments, relevant checks, ongoing assessment and verification of ongoing credit worthiness and standing;
- organizing and facilitating events, tournaments or programmes, including organizing and facilitating events, tournaments or programmes for members of SBA and verifying the eligibility of the said members to participate in such events, tournaments or programmes;
- promotional and publicity purposes, including recording of videos or taking photographs of the individual at events, tournaments or programmes;
- awarding of scholarships and training awards to members of SBA, including verifying the eligibility of the said members to receive such scholarships and awards;
- carrying out due diligence or other screening activities (including background checks) inaccordance with legal or regulatory obligations or risk management procedures (including but not limited to those designed to combat financial crime, “know-your customer”, anti-money laundering, counter-terrorist financing or anti-bribery), that may be required by law or that may have been put in place by SBA;
- dealing in any matters relating to the services and/or benefits which an individual is entitled to under this Privacy Policy (including the printing of membership cards and the printing and mailing of correspondence, statements, invoices, confirmations, advices, information, reports or notices, which could involve disclosure of certain personal data about an individual to bring about delivery of the same as well as on the external cover of envelopes/mail packages);
- the recovery of any and all amounts owed to SBA;
- investigation purposes, including for disciplinary cases, which may include or necessitate the viewing of images, including video recordings, CCTV recordings and photographs of an individual;
- safety and security purposes, including recording and verifying the individual’s identity in SBA’s premises and managing and monitoring the individual’s activities within SBA’s premises;
- preventing, detecting and investigating fraud, misconduct, any unlawful action or omission, whether relating to the individual’s application or any other matter relating to your application for SBA’s services and benefits, and whether or not there is any suspicion of the aforementioned;
- managing SBA’S infrastructure and operations;
- complying with policies and procedures that may be required by law or that may have been put in place by SBA, including those relating to auditing, finance and accounting, billing and collections, IT systems, data and website hosting, training, testing, operational continuity, and records, document and print management;
- complying with laws, regulations, codes or guidelines binding on SBA including disclosures to regulatory authorities or other public bodies;
- if consented by the individual, via the individual’s registration or participation in any contest,lucky draw, campaign, promotion, event, survey or questionnaire, to administer and provide the individual with such activities. Some of these activities have additional terms and conditions, which could contain additional information about how SBA uses and discloses an individual’s personal data, so SBA encourages that you read the said additional terms and conditions carefully;
- legal purposes or obtaining legal advice;
- complying with applicable law in administering and managing an individual’s relationship with SBA; and/or
- unless the individual has opted-out, provide for the dispatch of marketing information relating to services or benefits offered by SBA and SBA’S affiliates, partners and related companies which SBA thinks is of benefit or interest to the individual via postal mail, electronic transmission to your email address(es), and/or voice call or phone call, SMS/MMS (text messages), and/or fax.
(collectively, the “Purposes”).
Disclosure of Information
In carrying out one or more of the above Purposes, SBA may need to disclose an individual’s personal data to any third parties, whether located within or outside Singapore, including but not limited to:
- SBA’s partners, including but not limited to the Singapore National Olympic Council, Singapore Sports Council, Badminton World Federation, Badminton Asia and the SBA Badminton Academy, which SBA is collaborating with for one or more of the above Purposes;
- insurer or insurance brokers;
- service providers or agents including but not limited to those who provide administrative, telecommunications, computer, payment or securities clearing or other services to SBA in connection with the operation of its operations, mailing houses, telecommunication companies, marketing agents, call centres, data processing companies and information technology companies;
- individuals, organisations and/or any government authority who have provided scholarships, financial assistance, awards, medals or prizes during the period of an individual’s membership with SBA;
- SBA’s professional advisors, including accountants, auditors and solicitors;
- any person to whom disclosure is permitted or required by any statutory provision or law;
- any permitted assigns; and
- any local or foreign regulatory body, government agency, statutory board, ministry, departments or other government bodies and/or its officials.
Consent
SBA will not collect, use and/or disclose an individual’s personal data without his/her consent except as provided for in this Privacy Policy or as required by law (for example, disclosure to the Courts or various Government departments) or if SBA genuinely believes it is necessary to (i) act under exigent circumstances to protect the rights, property or personal safety of their members or guests, or any member of the public; (ii) protect and defend the rights or interests or property of SBA; and/or (iii) obtaining legal advice.
SBA will take reasonable steps to highlight the purposes relevant to an individual at the point or time of collection of the individual’s personal data via appropriate means, including but not limited to:
- express provisions in contracts, application forms and/or registration forms to be signed with or submitted to SBA;
- notifications on SBA’s website;
- verbal communications;
- correspondence through mail, email or electronic messages.
SBA will inform the individual of purposes (whether intrinsic or optional) to the relationship between SBA or provision of services to such individuals whenever feasible. SBA reserves the right to decline to engage in the relevant relationship with an individual or provide any relevant services to him or her if that individual does not consent to SBA’s collection, use or disclosure of his or her personal data for those purposes that are intrinsic to the relationship or provision of services.
Individuals who voluntarily provide personal data to SBA for specified purposes; use or access SBA’s website or computer network; enter SBA’s premises and/or attend or participate in events/tournaments/programmes/activities organised by SBA will be deemed to have agreed and consented to SBA collecting, using and/or disclosing their personal data in the manner and/or for the purposes set forth in this Privacy Policy. In addition, individuals who voluntarily provide personal data to SBA for specified purposes will also be deemed to consent to the collection, use and disclosure of the said personal data by SBA for the purposes for which the said personal data had been provided to SBA.
An individual who provides SBA with the personal data of third parties, including but not limited to information regarding his or her spouse or children for any particular purpose, represents to SBA that consent has been obtained from the relevant third parties to allow SBA to collect, use and/or disclose their personal data for the relevant purpose(s) concerned. In such an instance, SBA will rely on the individual to inform these third parties that their personal data is being provided to SBA, and also to advise them about where they can find a copy of this Privacy Policy (i.e. on the SBA website).
Insofar as SBA collects personal data of an individual from any third party, for example, partners or associates of SBA, SBA will take reasonable steps to inform the relevant third party of SBA’s purpose(s) for collecting the personal data and also require the third party to obtain consent from the individual(s) concerned in order that the said personal data may be disclosed to and collected by SBA via that third party.
Withdrawal of Consent
An individual who wishes to withdraw his or her consent to the collection, use or disclosure of his or her personal data may at any time do so by writing to secretariat@singaporebadminton.org.sg stating the following information:
- Name and identification number
- Membership number (if a member of SBA);
- The reasons(s) for which the individual wishes to withdraw consent.
SBA may require up to 3 weeks, from the date of the individual’s notification or request, to respond and effect any change.
Please note that SBA may be unable to continue to provide certain benefits and/or services to an individual as a result of that individual’s withdrawal of consent, and that such withdrawal of consent will not affect any legal consequences arising from such withdrawal.
In the event that a member of SBA wishes to withhold or withdraw his or her consent for SBA to collect, use or disclose his / her personal data, please take note that:
- Where the collection, use or disclosure of the member’s personal data is necessary in order for SBA to administer and/or maintain and/orfurther his or her membership with SBA, the member’s withdrawal of consent in such situations may result in the SBA being unable to continue administering or maintaining or furthering his or her membership with SBA.
- That being said, a member of SBA may opt to withdraw his or her consent for SBA to collect, use or disclosure his or personal data for the following purposes, namely:
- For SBA to provide him or her with information, promotion or marketing materials inrelation to SBA’s organised events / tournaments / activities / programmes, offers and/or benefits being offered and/or made available to members of SBA; and/or
- For SBA to provide him or her with information regarding promotions, deals and/or other services being offered and/or made available to members of SBA by SBA’s third party and/or external vendors/suppliers,
although in such an instance, SBA may as such not be able to accord the said member concerned the full extent of the personalised and comprehensive membership experience that SBA had designed for its members.
Personal Data Collected before 2 July 2014
SBA will continue to use an individual’s personal data that was collected before 2 July 2014 for the purposes of which such personal data was collected, unless consent is withdrawn by that individual.
Do-Not-Call Registry
SBA will not send unsolicited telemarketing messages to Singapore telephone numbers through voice calls, text or fax messages registered on the Do-Not-Call Registry unless SBA has obtained the relevant individual’s clear and unambiguous consent in written or other accessible forms in order to comply with the PDPA.
SBA will continue to contact individuals at the telephone numbers provided to SBA for the continued operation of SBA and to perform the above Purposes.
Access, Correction, Verification and Notification of Changes in Personal Data
An individual may at any time request to (i) access his or her personal data held by SBA; (ii) know how his or her personal data has been or will be used by SBA; (iii) correct or update or delete any inaccurate or outdated personal data held by SBA. Such request(s) must be submitted in writing to SBA at secretariat@singaporebadminton.org.sg, and must include proof of that individual’s identity as well as specify any membership reference numbers or employee number, where applicable.
SBA may charge an administrative fee to cover the reasonable costs of retrieving the information and supplying it to the individual concerned. SBA may also refuse or restrict an individual’s request for access to his or her personal data, such as where the personal data relates to ongoing or anticipated legal or disciplinary proceedings, or where the request is frivolous or vexatious. If SBA denies or restricts any access, we will explain why as required by applicable laws.
Information voluntarily submitted by an individual to SBA shall prima facie be deemed complete and accurate. Each individual remains primarily responsible and liable to ensure that all the personal data that he/she submits to SBA is complete and accurate.
SBA shall also take reasonable steps to periodically verify personal data in its possession, taking into account the exigencies of its operations. However, it is the responsibility of each member and personnel of SBA to periodically update SBA of any changes that should be made to his or her personal data.
SBA shall not be held liable for any inability on its part to provide services to an individual if that individual does not notify SBA of any relevant changes to his or her personal data or fails to submit complete and accurate personal data to SBA.
Protection of Personal Data
SBA takes reasonable precautions to protect an individual’s personal data and store it securely. Reasonable steps are taken and reasonable security arrangements are made to prevent unauthorised access, collection, use, disclosure, copy, modification, disposal or similar risk to personal data in the SBA’s possession.
SBA will take reasonable steps to ensure that third parties who receive personal data from SBA protect such personal data in a manner consistent with this Privacy Policy and/or the PDPA and will not use such personal data for any other purposes other than those specified by SBA, by incorporating appropriate contractual terms in its written agreements with these third parties or the provision of a written undertaking from these third parties.
SBA is not responsible in any way for the security and/or management of personal data shared by individuals with third party websites accessible via links on SBA’s website, nor is it responsible for the privacy practices or the content of these websites.
Retention of Personal Data
SBA will retain personal data for the period necessary to fulfil the Purposes and any legal or operational purpose, after which SBA will take reasonable efforts to ensure that such personal data in their possession or under their control is destroyed.
In cases where an individual ceases to be a member or personnel of SBA, i.e. any person engaged under a contract of service or contract for service with SBA, management personnel, permanent or temporary employees, as well as trainees, interns and volunteers engaged by SBA from time to time, whether having terminated / resigned / defaulted his / her membership or terminated / dismissed / resigned as an employee, SBA has the right to retain that individual’s records and use his or her information for legal and/or operational purposes.
Changes to this Privacy Policy
SBA reserves the right to modify or change this Privacy Policy at any time. Any change or modification of this Privacy Policy will be posted on the SBA website. SBA encourages individuals to check the SBA website and the terms of this Privacy Policy regularly to keep up to date.
The continued use of our website and the acceptance or engagement of our services at SBA after any changes to this Privacy Policy constitutes consent to any such changes, to the extent that such consent is not otherwise expressly withdrawn.